Our operations are subject to a diverse set of local laws and cultures. Our employees are citizens of various countries as we operate worldwide. We support an inclusive workplace that promotes and values diversity.

We rely on our employees’ personal integrity to protect and enhance our reputation.

All employees shall:

• Comply with:
  
  • This code
  • Applicable laws and regulations
• Act and stop any known misconduct by either:
  
  • Their colleagues
  • Other personnel violating this code
• Report to office Senior Management, any suspected or observed violations of:
  • This code
  • Our policies
  • Applicable laws and regulations

If there is a conflict with the local law and this code, we shall seek advice from the office Senior Management. We prohibit retaliation against anyone reporting a good faith concern.

Malicious or bad faith allegations may lead to disciplinary action. Failing to follow this code can lead to disciplinary action, including termination.

Definitions

Employment

We shall treat all people with dignity. It is violation of our values by any conduct, showing disrespect to:

• Our employees
• Customers
• Professional customers
• Vendors
• Suppliers

Examples of unacceptable conduct are:

• Yelling
• Threats
• Intimidation
• Ridicule
• Rudeness
• Slurs
• Stereotyping
• Discrimination
• Physical, verbal or non-verbal harassment or abuse
• Offensive jokes
• Sexual advances
• Requests for sexual favors
• Any other unwelcome visual, verbal or physical conduct of sexual nature
• Unwelcome touching
• Invasion of personal space
• Ignoring the rights of others
• Slandering or malicious rumors
• Insensitivity to belief and customs of others

We are committed to providing a safe, healthy and drug-free workplace.

Under our employment conditions, we strictly prohibit:

• Using illegal drugs
• Consuming alcohol during working hours in our premises
• Working under drug or alcohol influence

Any employee violating these conditions is subject to immediate employment termination.

We are an equal opportunity employer. We commit in ensuring our employees work in a mutual respect environment. We shall not discriminate any associate or applicant against:

• Race
• Color
• Gender
• Sexual orientation
• Gender identity or expression
• Age
• Religion or belief
• Nationality
• Disability
• Protected veteran or other uniformed service status
• Any other characteristic

Conflicts of Interest

We shall not use or attempt to use our position with the Company to gain improper personal benefits.

Employees shall report to the office Senior Management, when:

• Being aware of an interest conflict
• Being concerned a conflict might develop

Corporate Opportunities

When opportunities arise, all employees shall advance the legitimate interest of the Company. Employees shall not:

• Compete with the Company
• Take personal advantage of business opportunities discovered during their employment

Confidentiality and Privacy

The unauthorized disclosure of confidential information has severe consequences to the Company and the employee. Employees may have access to:

• Proprietary and confidential business information
• Clients
• Suppliers

Any employee in possession of such information shall:

• Maintain the highest confidentiality degree
• Not disclose any personal information, unless obtaining express authorization
• Protect the confidentiality of Company information:
  • During their employment
  • After their employment
• Not use, disclose or communicate the confidential information

The restriction on confidential information disclosure shall not prevent employees from:

• Reporting concerns of any known or suspected code violation to the:
  • Senior Management
  • Government body or a regulator
• Reporting retaliation for reporting such concerns
• Responding truthfully to questions or request:
  • From a government body or regulator
  • As required by applicable law

Honest and Fair Dealing

Ethical conduct follows the accepted professional standards of conduct.

The employees shall:

• Deal honestly, ethically and fairly with Company’s:
  • Customers
  • Suppliers
  • Competitors
  • Employees
• Not take unfair advantage of anyone through:
  • Manipulation
  • Concealment
  • Abuse of privileged information
  • Misrepresentation of facts
  • Any other unfair dealing practice

Protection and Proper Use of Company Assets

Protection and Proper Use of Company Assets

Our assets are used only for legitimate business purposes by authorized employees or their deputies. Our assets can be either:

• Material, like:
  • Office equipment
  • Telephone
  • Copy machines
• Immaterial, like:
  • Trade secrets
  • Confidential information

All employees shall:

• Protect our assets from theft and loss
• Ensure their efficient use
• If becoming aware of their theft, waste or misuse, report it to their Manager

Note:   Theft, carelessness and waste of our assets have direct impact on our profitability.

Compliance with Laws, Rules and Regulations

Our policy is to comply with all applicable laws, rules and regulations.

Each employee shall follow the standards and restrictions imposed by these, especially those related to:

• Accounting matters
• Auditing matters

Note:   If in doubt for any violation of law, rule, regulation or our policy, contact the office Senior Management.

Anti-Corruption and Anti-Bribery

We shall follow the:

• UK Bribery Act 2010 (Bribery Act)
• Foreign Corrupt Practices Act (FCPA)
• Anti-Corruption Legislation

These acts prohibit the Company and any person performing services on our behalf from receiving, offering or promising or giving money or any other item of value to:

• Win or retain business
• Influence any 3rd party act or decision, even if the 3rd party is a public official
• Gain personal advantage

To ensure compliance with the Anti-Corruption Legislation, we have appointed an independent 3^rd party auditor. The auditor shall run annual and spot checks to detect and prevent any impropriety.

Warning!

Do not violate the Bribery Act of the FCPA. The violation is a crime and can result to fines and criminal penalties to the individual and the company.

The employees shall not:

• Directly or through intermediaries, offer or promise any personal or improper financial or other advantage to:
  
  • Obtain or retain business
  • Their advantage from a 3rd party, public or private
• Accept any advantage as a reward for preferential treatment to a 3^rd party
• Give the impression or suspicion of such act

Note:   For any queries on the Bribery Act and the FCPA, contact the office Senior Management.

Securities Trading

We are a public Company, subject to laws for our shares purchase and publicly traded securities.

Information is material when:

• Considered important by a reasonable investor, for deciding whether to buy, hold or sell the securities
• Affects the security prices

Information becomes public when:

• Released to the public through appropriate channels
• Enough time has passed for the investment market to absorb and evaluate the information

Note:   Any employee in doubt on the type of information shall contact their Manager or the office Senior Management.

Employees or their family members, shall not trade securities while in possession of material, non-public information related to:

• Our Company
• Any other company including:
  
  • Customer
  • Supplier

Disclosure

Employees shall:

• Ensure that the disclosure in our periodic reports is:
  
  • Full
  • Fair
  • Accurate
  • Timely
  • Understandable
• Confirm that our periodic reports comply with applicable:
  
  • Law
  • Rules
  • Regulations
• Ensure the information in our periodic reports fairly represents our:
  
  • Financial condition
  • Operation results
• Take appropriate actions to establish and comply with the:
  
  • Disclosure controls and procedures
  • Financial controls designed to ensure Company related material information is known

Employees shall not knowingly:

• Make, permit or direct another to make materially false or misleading entries in the financial statements or records of:
  
  • Our Company
  • Any of its subsidiaries
• Fail to correct materially false and misleading financial statements or records
• Sign or let another to sign a document containing information:
  
  • Materially false
  • Misleading
• Falsely respond or fail to respond to specific inquires of our either:
  
  • Independent auditor
  • External legal counsel

Procedures for Waivers

We shall grant waives only:

• In limited circumstances
• Where such circumstances support a waiver

The Audit Committee shall only make waivers of this code and disclose them to the Company.

Modern Slavery and Human Trafficking Statement

We are committed to act with integrity for our:

• Clients
• People
• Suppliers
• Wider community

We are committed to the human rights respect. We follow the UN’s Guiding Principles on business and human rights. Following this principle, we shall:

• Avoid causing or contributing to adverse human rights impacts through our activities
• Address any impacts, when such occur
• Prevent or mitigate adverse human rights impacts, through our business relationships directly related to our:
  
  • Operations
  • Products
  • Services

To show our commitment to the UK Modern Slavery Act 2015 we shall:

• Recognize our responsibility to eradicate:
  
  • Slavery
  • Human trafficking
• Ensure there is no modern slavery or human trafficking within our business
• Use suppliers:
  
  • Compliant with our values and policies on this matter
  • Not engaged to such practices